Request for officer assignments and interactions with RFI tags 12679304000 (00:11) Welcome to ring central conferencing. 12679304000 (00:20) Correct access code, please re-enter your access code, followed by the pound. 12679304000 (00:45) Access code accepted. 12679304000 (00:47) You are the only participant in this conference. 12679304000 (03:27) Ellen Lewis. Me (03:42) Yeah, it's been. 12679304000 (03:45) Are you there? 12679304000 and Me (03:46) Can we hear me? I can hear Me (03:48) you. 12679304000 and Me (03:48) Yes, I can hear email. Do you hear me? 12679304000 (03:52) I just sent you an email because back I don't know that we even need to have a phone number because I have you know I'm not in the sheriff's office. 12679304000 (04:03) Obviously if I don't have access to documentation. 12679304000 (04:10) And so I received your list of all the information you need to identify the dough defendants, and so I'll conference with my response to see if those things exist and provide what I can provide to you pursuant to the federal federal rule of civil procedure based on what exists and does not exist, but I mean it looks like I mean. 12679304000 (04:34) Are you asking for your entire? 12679304000 and Me (04:38) Everyone who worked in every single pod? Yes, ma'am. 12679304000 (04:41) From June 9th until September 4th. Me (04:44) Not every single pod, just who was assigned to F pod and who did rounds, and F pods, they had R FI D tags in the pod, so they know what officer went in there, and with that I can say who the interaction was and what happened, those R FI D tags on the pil on the the pill cart, I guess you'd call it, so they know what officer did that. Me (05:05) That is what I'm after, so I can identify this. Me (05:07) You do have my list, and I'm okay with wrappings up quickly. Me (05:10) Let's slip quick, real quickly. Me (05:12) Do you object to me seeking any of that? 12679304000 (05:17) I had not had the chance to really dig into the legal analysis of your request. 12679304000 (05:25) I hope for example. 12679304000 (05:30) Now I need to put every game in rotting. 12679304000 (05:37) As well, and so I can't really say right now on the phone, whether or not I object or don't object, is my understanding from talking to my client that the third party medical school does till fall, but I'll have to speak with him about that again and say, maybe and see exactly what the policy is surrounding that I do not have any of the information for any of the third party medical employees or their records, and so that's something that would have to come directly from them, so I would object to anything that had to do with the medical care provided, of course, but the rest of the things. 12679304000 (06:09) All have to look into it because I've not been able to, you know, look at it quickly because I'd use it in the email 13 minutes ago and look at it and do it analysis, and I can't just kind of be that on the fly. Me (06:22) Okay, and I do wanna make one thing clear, like I said they had R FAD R FI D tags on the till call the county maintained that not turnkey, so the county maintains those records, and those are records that would allow me to identify who escorted the pill called nurse around because they got to where they were taking their name tags off just because they knew I was writing things down and taking notes, but I paid attention there were still cameras within view and they were still, they had a tag that little rfad tag on the cell door or inside the tag inside the pod. Me (06:49) So county maintains those records. Me (06:51) That's what I'm after turnkey, has given me some stuff that I'll deal with turnkey on that. Me (06:57) What I'm seeking is narrowly in define, this is what Nota county has so, and also the deadlines approaching, and I don't wanna keep filing and asking, you know. Me (07:07) Motion to compel, so if we can work something out quickly, that'd be greatly appreciated. Me (07:11) So is there any time you can review this hopefully by the end of tomorrow and get back to Me Before You leave tomorrow, that way we can kind of set a date maybe next week to confer. 12679304000 (07:22) And well, I can review it. 12679304000 (07:24) Yeah, but I mean, I'm not going to be able to get it down by tomorrow. 12679304000 (07:27) I don't know. 12679304000 (07:27) I mean that's just because of other commitments like I have this conference followed with another court on the case with the court on another case at 2 o'clock today, and I don't know what. 12679304000 (07:41) Gathering some of these records might take longer than you would anticipate, so I will or take longer than I have no idea and so I'm going to reach out to the county and request them and I'll keep you updated on how this goes and wins the deadline which identify the dog descendants in this case. 12679304000 (07:58) Is just the one that was extended? 12679304000 (07:59) I'm looking at the case. 12679304000 (08:01) That is, case number 426D118. 12679304000 and Me (08:08) So you have, what's Intel, September 1st. The 118 is the one? Yeah, the oneone8 is the one that I'm kind of Me (08:10) concerned about the other one was they've judged, gave me more time, and I'm fine with that one. 12679304000 (08:19) All right, so the 11 I you have until September 1st. 12679304000 (08:22) 2. 12679304000 (08:28) And so I don't think they'll be able to get in touch with the or get everything back to you by the end of the day tomorrow, but I'll work on the information and keep you updated as soon as I gather everything, but I mean, I think if I could have two weeks and I mean, because these are some of this is new discovery requests that you spent over, like specific issues regarding maintenance and stuff like that. 12679304000 (08:49) That is not things that I've seen before. 12679304000 (08:51) And so if we can work on having two weeks until August 20th, that would be great. Me (08:56) I think that's more the reasonable, and the reason you 're just seeing it, like in this in total, different case, I know your counts on both these cases. Me (09:02) So that's that's why that's happening. Me (09:05) And just once again to regenerate, if you can get those R FI D logs. Me (09:08) And get them to meet and a complete robster, I can do all the leg working boy of hanging out with the notes that I have and slot bugging you so much. 12679304000 (09:19) I'm going to email you right for our phone or actually conversation today. 12679304000 (09:24) I'm going to respond to these requests in 14 days about just 20. 12679304000 (09:35) All right. 12679304000 and Me (09:36) Thank you, Michelle and appreciate it. Thank Me (09:37) you. Me (09:37) You have a blessed weekend.